…the payment processor did not follow its own guidelines for new merchants and did not check addresses, phone numbers, or references the bogus merchant provided. The FTC alleged that the defendants anticipated that the scam would generate high return rates, that they did not request or obtain proof that consumers had authorized debits to their accounts, and that they continued to process charges even after receiving complaints from consumers and banks and unacceptable explanations about unauthorized debits from the merchant. The complaint alleged that more than 70 percent of the merchant’s transactions were returned or refused by the consumers’ banks

Guidelines and proper business practices are NOT check boxes for the sole purpose of checking them, but to be adhered in a manner that ensures the operational integrity of the business and the fidelity of operations.